I would, because Medicare covers physicals in very narrow specific circumstances (The "Welcome to Medicare" physical), so you can't say that it is NEVER covered and ABN isn't necessary. I should have said earlier that Medicare doesn't cover ROUTINE physicals.

I would also review the chart to see if anything was found and see if it really qualified for a regular E&M code. When I was in primary care, the doc I worked for would say "schedule this patient for a physical" and when I said, "Medicare won't pay for a physical" he smiled and said, "they're over 65... I'm sure there is SOMETHING wrong I need to check on." So he wanted the longer time slot that a physical was scheduled for, so that he could do a more comprehensive review of all of their systems. And I saw his charts, and he was right, most had a minimum of two, and usually about four or five, chronic problems or problems that come with age. And since he saw some of these people only once or twice a year, this gave him adequate time to order tests and whatnot and make sure ALL of their illnesses were addressed.